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Issues: Whether a return of income filed with the Income-tax Department at Jaipur, instead of the officer having territorial jurisdiction at Guwahati, could be treated as invalid and whether the Revenue's grievance against the CIT(A)'s direction to treat such return as valid had merit.
Analysis: The return was admittedly filed with the Department and no material was brought to disprove that filing. The fact that it was lodged before an officer lacking the correct territorial jurisdiction did not, by itself, render the return invalid. The proper course was for the receiving office to transmit the return to the officer having jurisdiction and for that officer to call for it. A departmental lapse in internal handling could not defeat the validity of a return already filed.
Conclusion: The return filed at Jaipur was held to be a valid return and the direction to treat it as such was upheld.
Final Conclusion: The Revenue's challenge failed and the assessment made by disregarding the return could not be sustained.
Ratio Decidendi: A return filed with the Income-tax Department cannot be treated as invalid merely because it was presented before an officer lacking territorial jurisdiction, where the filing itself is proved and the defect lies only in the department's internal handling.